Written evidence submitted by the Secretaries
to the Boundary Commissions (PVSCB 04)
INTRODUCTION
1. This evidence only addresses Part 2 of
the Bill, since Part 1 deals with matters in which the Commissions
have no locus. However, we note that since both First-Past-The-Post
and Alternative Vote result in the election of a single member
for each constituency, the requirements of constituency design
will be the same for both systems.
2. We will be happy to discuss any of the
matters in this evidence when we attend the Committee's evidence
session. The evidence has been divided into the following general
topics:
— the resource implications for the Commissions
of the review process provided for in the Bill;
— the practical implications of the rules
as set out in the Bill for the approach by Commissions to a review;
— the provisions in the Bill on consultation;
and
RESOURCE IMPLICATIONS
3. The changes to the review process will
reduce the resource requirement of each review slightly, but the
frequency of reviews will be approximately twice the present frequency.
The effect of the Bill will be to increase the overall resources
required for boundary reviews, because of the increased frequency
of reviews. The Secretariats have estimated that, for the Bill
as introduced, the first reviews after its passage would cost
a total of £12.8 million across all four countries. The corresponding
cost of the last reviews (5th Periodic Reviews) was £13.6
million.
4. The resource estimates have been made
prior to decisions by the Commissions on how best to carry out
the review. Also, estimates have been made on the provisions of
the Bill as introduced: amendments to the Bill may have resource
implications.
5. We note that Commissions will retain
the power to request the appointment of Assistant Commissioners,
and may wish to exercise that power to obtain expert assistance
in assessing and reporting on written representations.
6. Currently within the Welsh and Scottish
Commissions, Secretariat staff are continuously employed, with
their tasks changing between Westminster, devolved body and local
government reviews (since the Secretariats also supports the Local
Government Boundary Commissions in those countries). The Bill
would increase the variability of the workload making the recruitment
and retention of staff with the specialist skills required more
important for the future.
7. In the Secretariat to the Boundary Commission
for England, where the Commission Secretariat only supports parliamentary
boundary work, the opposite situation applies: the Bill will provide
near-continuous work, thereby improving core staff stability.
8. In Northern Ireland, the Secretariat
only supports parliamentary boundary work. However, the Secretariat
is only in place for the duration of a Review. Between reviews,
the Commission operates on a "care and maintenance"
basis with a Secretary nominated by the Secretary of State with
concomitant difficulties in recruiting and retaining experienced
staff.
PRACTICAL IMPLICATIONS
9. When designing constituencies, each Commission
develops a scheme that fits the whole of its area of responsibility.
Therefore it is not possible to say that constituency design has
any particular geographic starting point.
10. The changes to the total number of constituencies,
and the tighter limits on the number of electors in each constituency,
will result in a complete redrawing of constituency boundaries.
11. Many of the practical implications of
the Bill result from the electoral parity target to be applied
under the new Rule 2(1). The electoral parity target may require
the Commissions to work with electorate data below ward level
in many cases.
12. In Scotland, the General Register Office
for Scotland (GROS) produces a six-monthly map dataset showing
the extent of each postcode. When conducting a review, the Boundary
Commission for Scotland collates electoral register data to count
electors for each postcode, and then combines that with the GROS
data. That allows the Commission to count electors by very small
areas: there are around 140,000 unit postcodes and four million
electors in Scotland, therefore the average number of electors
per unit postcode is less than 30.
13. Even working with electorate aggregated
by unit postcode, there is a small degree of uncertainty in the
data. This uncertainty arises since the electoral register contains
a number of entries with incomplete or inaccurate postcodes.
14. In Scotland, England and Wales, Ordnance
Survey produces a unit postcode boundary product which is sufficient,
although not as detailed as the GROS product in Scotland.
15. The English Commission has not developed
the necessary procedures to work with the full electoral register
data because, hitherto, it has not needed to. The number of electors
(in excess of 38m) and Electoral Registration Officers (326) would
make this a very large task.
16. In Wales, early modelling suggests that
the required electoral parity may be achieved by using electoral
divisions (wards) as building blocks for constituencies. Should
a smaller unit be required, communities (parishes) are defined
across all of Wales. Thus, the Welsh Commission expects that it
will be able to use a consistent and recognisable approach to
constituency design across Wales.
17. In Northern Ireland, the building block
for constituencies will be the local government ward. However,
in order to achieve electoral parity it is likely that, in some
cases, wards will be divided between constituencies. The software
in use in Northern Ireland is sufficiently flexible to allow a
range of such units to be employed, such as townlands (which are
a unique feature in Ireland), postcodes, or Census output areas.
18. The Bill limits the maximum area of
any constituency, and exempts constituencies close to this maximum
from the lower limit on electoral parity. This only applies if
a Commission is satisfied that it is "not reasonably possible"
to meet the electoral parity target. The geography of the United
Kingdom means that this exemption will only apply in highland
Scotland. The Scottish Commission will examine how to design constituencies
within these new rules: the Secretariat's current view is that
there are likely to be 0, 1 or 2 constituencies to which this
exemption applies.
19. The electoral parity target will result
in many constituencies crossing local authority boundaries. Early
modelling suggests that in Scotland between 15 and 20 constituencies
(of 50), and in Wales between 23 and 28 constituencies (of 30),
would cross a local authority boundary.
20. In England, the Commission first recommended
constituencies that crossed London borough boundaries at its fourth
general review. At its fifth general review, in order to recommend
constituencies with electorates closer to the electoral quota,
it crossed boundaries to a much greater extent—34 constituencies
crossed a London borough, Non-Metropolitan County, or Unitary
Authority boundary. It expects to cross boundaries to an even
greater extent in a review carried out under the terms of the
Bill.
21. In Northern Ireland, for many years
constituency boundaries have generally crossed local authority
boundaries due to the small size of most local authority areas,
and the resulting difficulties in achieving parity.
22. It is likely that the English and Scottish
Commissions will want to take local authority areas into account
when designing constituencies. As part of that, each Commission
may wish to identify which local authority areas to group together
for constituency design at an early stage of a review. In Wales,
local authority boundaries will be taken into account wherever
possible, but as noted above, most constituencies are likely to
cross a local authority boundary.
23. The Bill continues to give the Commissions
discretion in constituency design, within the electoral parity
and area requirements. We believe that this discretion is essential
in order to retain a local dimension to an otherwise mathematical
exercise.
24. However, the application of the electoral
parity target is likely to result in many communities feeling
that they are being divided between constituencies.
CONSULTATION
25. The Commissions' experience is that
while local inquiries have served a useful function, many of those
attending have a specific party political affiliation which significantly
determines their evidence. While local inquiries may not have
been a frequently-used way for ordinary members of the public
to engage with a review, they provide an opportunity for all to
present their views. In practice, the main participants at inquiries
have been representatives of political parties and local authorities.
While most of the issues which are raised are presented through
written evidence to the Commission, others only emerge at an inquiry.
26. A longer consultation period may improve
the quality of arguments and evidence presented in written submissions
for two reasons: it will be the only means of presenting an argument,
and a 12 week consultation period will allow for more detailed
preparation of an argument. The Bill does not specify the means
of making representations. We believe it should specify written
representations, to allow full and fair assessment of all representations.
27. Local inquiries, chaired by a person
skilled in dealing with and assessing evidence, are a useful process
for forming a judgement on the arguments presented. That task
will now fall to the Commissions, and will take time to carry
out thoroughly.
28. Schedule 1 to the 1986 Act is not amended
by the Bill, and allows a Commission to request the appointment
of Assistant Commissioners. It may be that a Commission may still
find it useful to ask an Assistant Commissioner to assess and
evaluate written evidence submitted to the Commission.
OTHER ISSUES
29. The process for Scottish Parliament
boundary reviews is defined in separate legislation, and is almost
identical to the current process for reviewing Westminster constituencies.
The Bill will result in substantial difference between the two
processes. This is likely to be confusing for those involved,
and there would be benefits in ensuring that the review processes
for Scottish Parliament reviews and Westminster reviews remain
the same.
30. The Bill decouples Welsh Assembly constituencies
from Westminster constituencies and removes any power to review
Welsh Assembly constituencies after the completion of a set of
interim reviews currently in progress. There do not appear to
be any current plans to introduce legislation setting out the
timing and process of future Welsh Assembly constituency reviews.
The timing of such reviews will have an important impact on how
the joint secretariat will efficiently manage its resources for
local government, Westminster and Welsh Assembly reviews, assuming
that there will still be a requirement for this.
31. The constituencies for the Northern
Ireland Assembly are the same as the Westminster constituencies,
with six Assembly seats for each constituency. The link between
Westminster and Northern Ireland Assembly constituencies is not
altered by the Bill.
32. Strict electoral parity, and a fixed
total number of constituencies, will result in frequent constituency
redesign. For example, looking at electorate data from the last
10 years, Scotland's, England's and Northern Ireland's allocation
of constituencies would have changed on each occasion if reviews
had been held 5-yearly since 2000. Wales' allocation would have
been unchanged. When the number of constituencies in a country
changes, it is likely that many constituencies will have to change
in order to ensure continued compliance with electoral parity.
Bob Farrance
Secretary, Boundary Commission for England
Liz Benson
Secretary, Boundary Commission for Northern Ireland
Hugh Buchanan
Secretary, Boundary Commission for Scotland
Edward Lewis
Secretary, Boundary Commission for Wales
2 September 2010
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